From: Brunk, Debra [mailto:DBrunk@AHAM.org]

Sent: Wednesday, April 08, 2009 10:13 AM

To: Edwards, Brenda

Cc: Khan, Mohammed; McGuire, Joseph; Messne r, Kevin; Morris, Wayne; Samuels, Chuck

Subject: AHAM Response to Letter with subject "Request for information regarding possible

standby and off mode energy use for unvented heaters"

Dear Ms. Edwards,

Please find AHAM’s response to DOE’s March 23, 2009 letter addressed to portable

electric heater manufacturers requesting information on standby mode and off mode

use of these products. It is our position that these products should be exempted from

the proposed test procedure change as these products do not have a st andby mode and

there is currently no test procedure to measure energy consumption. However, if DOE

chooses to move forward with the test procedure rulemaking on residential portable

electric heaters, please feel free to contact me and we will work with our members to

provide what information we can.

Best regards,

Debra

Debra K. Brunk, Ph.D.

Vice President, Technical Services

1111 19th Street NW, Suite 402, Washington, DC 20036

t 202.872.5955 ext314 f 202.872.9354 e dbrunk@aham.org

www.aham.orgApril 8, 2009

Ms Brenda Edwards

U.S. Department of Energy

Office of EERE

Mail Stop EE2J

1000 Independence Avenue,SW

Washington, DC 20585

Dear Ms. Edwards:

The Association of Home Appliances (AHAM) is the trade association representing the

manufacturers of major, portable and floor care home appliances, and suppliers to the industry.

Through our Portable Appliance Divisi on, we represent manufacturers of portable electric

heaters. It has come to our attention that manufacturers of portable electric heaters received a

letter from the Department of Energy requesting information on possible standby and off mode

energy use, as required by EISA 2007.

AHAM recognizes the requirements set out in EISA 2007, which state “For residential water

heaters, direct heating equipment, and pool heaters, DOE must prescribe any such amendment

to the test procedures by March 21, 2010”. While “direct heating equipment” is not defined in

10 CFR 430.2, AHAM recognizes that EPCA provided the DOE with the authority to prescribe

standards for home heating equipment, which includes vented and unvented products.

Unvented products have been exclu ded from the current energy efficiency rulemaking on direct

heating products since the unvented test procedure (Appendix G to Subpart B or 10 CFR 430)

does not provide a method for determining energy efficiency or consumption. AHAM’s

comments relate only to residential portable electric heaters

.

With regard to standby power measurement, AHAM supports the IEC 62301 definitions, and

has developed guidelines (already communicated to the DOE) that further clarify these

definitions for home appliances. We have included these guidelines with this letter for your

convenience. We believe these guidelines can assist the Department in development of test

procedures for standby power.

It is our pos ition that portable electric heaters operate only in an active mode. Manufacturers

of portable electric heaters are required to state the following on the cord tag and in the

instruction manual: “Al ways unplug heater when not in use (This item may be omitted if thep 2 heater is provided with a clock

‐ operated switch)” (UL 1278, Sections 64.13 and 65.2; UL 1042,

Sections 54A and 55.3). To our knowledge there are very few, if any, portable electric heaters

outfitted with a clock

‐ operated switch. Consumer data, collected by The Stevenson Group for

AHAM in 2004, recognizes that 86% of consumers unplug thei r portable electric heaters per the

safety instructions. IEC 62301 states that standby and off mode power is for products that are

connected to a mains power supply. Since this product is unplugged when not in use, only

active mode is applicable to portable electric heaters.

In addition, AHAM supports the EISA 2007 requirement to integrate standby mode and off

mode energy consumption into the overall ener gy efficiency of the product unless the test

procedure already includes a method or it is judged to be technically infeasible. However, a

test procedure to determine active energy use for unvented heating products, and specifically

portable electric heaters, must first be developed in order for standby mode and off mode

power to be incorporated into the total energy consumption.

Based on the lack of test procedure to determine energy consumption and the safety

requirements noted above, we request that DOE exempt portable electric heaters from the test

procedure and rulemaking activities with regard to standby energy.

Sincerely,

Debra K. Brunk, Ph.D.

Vice President, Technical Services

Cc: Mohammed Khan, Department of Energy

Joseph McGuire, AHAM President

Kevin Messner, AHAM Vice President, Government Relations

Wayne Morris, AHAM Vice President, Division Services

Chuck Samuels, AHAM Legal Counsel